Why the Scottish Home Report Doesn’t Work for England and Wales

Every so often, I hear someone say, “Why can’t we just adopt the Scottish Home Report in England and Wales? Wouldn’t that solve everything?”

It’s a fair question. On the surface, the Scottish system looks neat and consumer-friendly: one report, paid for by the seller, made available at the point of marketing. Buyers get upfront information, and everyone knows where they stand. Compared to the patchwork of surveys, searches, and conveyancing hurdles elsewhere in the UK, it may seem like an easy fix.

But in reality? It’s not that simple. Here’s why.

What the Scottish Home Report actually does

Since 2008, every home put on the market in Scotland (with some exceptions) needs a Home Report. This includes:

• Single Survey: a property condition survey prepared by a chartered surveyor.
• Energy Report: the EPC.
• Property Questionnaire: completed by the seller with details like planning permissions, alterations, council tax, and utilities.
  
  

The idea is that the buyer sees this upfront before making an offer. Sellers pay for it, and surveyors are instructed directly by them.

The appeal - and the misunderstanding

To buyers in England and Wales, where the process is often stressful and opaque, the Scottish model sounds like a dream:

• Clarity upfront - no nasty surprises later.
• Fairness - every buyer sees the same survey.
• Efficiency - fewer fall-throughs.
  
  

But this assumes two things that don’t line up with how the market works elsewhere:

1. That one survey suits every buyer’s needs.
   
2. That the legal, lending, and offer processes are the same (they’re not).
   
   

Why it doesn’t translate

Different legal systems
Scotland’s property law is fundamentally different. Offers become binding much earlier. In England and Wales, we don’t have that framework - so even with a Home Report, buyers could still pull out late in the process.

The “offers over” system
In Scotland, most properties are marketed at “offers over” the advertised price. Bidders all see the same survey, then submit sealed offers. This works because the report underpins a specific legal and market framework. In England and Wales, buyers negotiate in a more open-ended way and often need their own advice on condition and value.

Lender requirements
Scottish lenders typically rely on the Single Survey, but in England and Wales most lenders still want their own valuation — or increasingly, use desktop/automated models. A seller-commissioned report here wouldn’t remove the need for separate checks, and panel restrictions could even reduce independence and choice of advice.

Risk and liability
In Scotland, surveyors know their reports may be relied upon by multiple buyers. That increases liability and requires different insurance structures. Extending that model to England and Wales would increase risk and cost. Importantly, the Single Survey provides condition information, not advice — it is not equivalent to an RICS Level 2 or Level 3.

Market behaviour
Scottish sellers accept they must pay for due diligence upfront; buyers accept they must pay to make an offer. The culture in England and Wales is different: sellers want a cheap route to market, and buyers want tailored advice that fits their needs.

Lessons for the Home Survey Standard

The current HSS consultation doesn’t address these wider reform questions. Its focus is on scope, clarity, and consistency - important issues, but arguably too narrow.

The now-defunct Property Surveyors Sub-Group (PSSG), working with the Home Buying and Selling Council, offered a broader way forward: a triage model that identifies risky properties, commissions proportionate checks, and provides consumers with clear “if this, then that” guidance. This kind of layered, risk-based approach reflects how buyers actually behave.

By not exploring such models, the HSS risks being too inward-looking - focused on wording and compliance rather than addressing systemic frustrations for consumers and inefficiencies across the chain.

But why can’t we have both?

Imagine a system where:

• Baseline, standardised condition information is available upfront.
• Surveyor advice then builds on that baseline, tailored to the client’s needs and future plans.
  
  

That way, consumers benefit from both clarity and confidence, and surveyors maintain their professional role as trusted advisers.

The Scottish Home Report works in Scotland because the legal system, offer process, and lender practices all support it. It is not a direct solution for England and Wales. But its principles - clarity, certainty, and upfront information - are worth learning from.

What we need is a system designed for our market: one that blends upfront material information, triage pathways, and layered surveyor advice.

Why It Matters

Calls to import the Scottish model show a hunger for change. But copy-and-paste won’t work. To deliver real reform, we need a system rooted in our legal framework, market culture, and consumer needs — one that provides upfront clarity while preserving the independent advice that only surveyors can give.

A Personal Note

These thoughts come from my experience of over 20 years in surveying and supporting both consumers and surveyors. They’re simply my perspective - shared to open up discussion and encourage more voices to feed into the consultation. If you have a view, please take a moment to respond - your input really does make a difference. This is the link to the consultation.

Enjoyed this article?

• You might also like: Consumer Products Get Tested, So Why Not The Home Survey Standard?
• Find it useful? Please share it with friends or colleagues who might benefit.
• Want to support my work? Leave me a quick Google Review or Buy Me a Coffee ☕. Every little helps as a small business.